In June of 2007 Clark County Nevada District Court Judge Susan Johnson ordered Shannon Hart aka Shannon Hudnell aka Lucidity to remove all postings regarding us. Shannon Hart aka Shannon Hudnell failed to comply hence this public request two years after the Order from the Judge and four years after Shannon Hart aka Shannon Hudnell posted a Rip Off Report under the alias of “Juliana”

September 24, 2009

Dear Shannon Hudnell:

It has been almost five years from that date of your infamous modeling session of April 2005. Since that time you have posted a number of EZ Background Reports and Rip Off Reports utilizing numerous aliases most recently updating your report filed on August 2, 2005 Rip Off Report #152280 where you posed as “Juliana”. Our update was filed on September 18, 2009 in less than one calendar day after that you filed two {2} additional updates.

For someone who claims that she has moved on with her life and “forgotten” about this report your actions speak for themselves. In truth you probably did forget about this web site and the pain you inflict on others allowing these postings to remain to the detriment of other people who have reputations, home addresses, work addresses, phone numbers, and have needlessly suffered because you cross posted all of their professional contact information online; people with bills to pay and people with problems just like you. People you refer to as “losers”

The legal actions you refer to continue in the courts. We did seek a strategic default in the case of Zenity Foundation when our attorney performed so poorly at your trial. Remember MODEL corporations are considered separate entities {persons} and must be represented by counsel. The prevailing parties were awarded a paper judgment effectively worth nothing since we were forced to stop writing business after you and your co-conspirators defamed Zenity Foundation in a plethora of online cross indexed postings.

As we were researching our case we learned that this wasn’t your first foray into committing multiple acts of harassment, stalking and defamation against innocent people.

When asked about the online posting regarding Florida law enforcement officers you surreptitiously photographed while they were enjoying a night out at a local tavern and because you had a beef with one of the officers {he dumped you} or whatever; you designed cartoon bubbles over their heads and inserted language depicting them as involved in “gay banter” then you substituted the beer one of the officers was drinking for a black penis that was ejaculating semen on his face.

You claim though that you made up with him {them} and everything is just fine. Maybe in your mind! Model when you were asked about this depiction of degrading other human beings especially Florida Police Officers during your court ordered deposition you laughed!

But your alleged sociopath compulsions commenced well before your deposition. You were represented “pro bono” by one of the most prominent law firms in all of Las Vegas. Clay Hendrix. Your attorney was Mr. Christensen. So when you say in your update that:

“The first attorney "pro bono" that they speak of is only partially true, as Clay Hendrix was not the attorney representing me, and it was his rude wife that called me, not my attorney's wife.”

But your defaming of your own legal team was more heinous because of the sexual emasculation you proffered regarding him and the wife of your lead counsel and because attorney’s livelihoods are traded on their reputations were you attempting to destroy them too with your sexually vulgar tirade?

In any case they withdrew from the case and your assumption that attorney’s providing service “pro bono” do not perform as well with paying clients is simply not true. An attorney’s reputation is the only thing they have to market themselves. Each and every case is crucially important. You were receiving the best representation available by any firm in Las Vegas and it was “free” but since you exhibit such anti-social proclivities or were hung over when the woman made a simple request for you to cover some “incidentals” you destroyed the relationship. You were receiving “free” representation from a firm that charges paying clients over $350.00 per hour and you still had to have the last word.

Was it sabotage as deep down inside you didn’t think you deserved such excellent counsel to extract you from a defamation case or Model was it the booze talking instead of you?

Your current attorney G. Luke Ciciliano is representing you and your case pending before the Supreme Court of Nevada, We accept that we did not prevail mainly because defamation cases are very hard to prove and our attorney was not sufficiently prepared for trial. .

You didn’t prevail either but since you made an “offer of judgment” against us for $15,000.00 or in other words you wanted us to pay you for the privilege of having you harass, stalk and post a plethora of rip off reports online not to mention the thousands of prank calls you initiated against us at all hours of the day and night from places like transmission repair shops in Florida even though we reside in Las Vegas.

We appreciate that an “offer of judgment” is a tool if brought in good faith for

either party to bring a swift resolution to the legal proceedings saving both parties thousands of dollars in fee’s and eliminating the stress of discovery and trial.

However if the party, Shannon Hudnell, does not gain a more favorable advantage than that offered by the offer of judgment then you, Shannon Hudnell are required to pay the legal fees of the other parties from the time you made the offer of judgment. [1]

Since you did not prevail and were awarded nothing by the court and each count of your frivolous counterclaim was dismissed you owe all parties that were required to defend themselves against your claims their attorneys fees from the time you made your offer of judgment. Shannon Hudnell, you knew your case was on appeal, Right? Prevailing parties don’t appeal their cases.

Shannon Hudnell we absolutely love your comfort level with your new attorney G. Luke Ciciliano. You traded in one of the most effective litigators in Clark County, Nevada who worked for free for a guy who split from his last office in such a hurry he left his sign and some files behind.

G. Luke Ciciliano rents an office about three blocks from his last known address which was nestled just behind the Federal Courthouse. It was a nice little house in a relatively safe area of downtown. His new digs are pushing into the badlands of the city of Las Vegas adjacent to boarded up buildings throughout the neighborhood. It’s a far cry from the Office of Clay Hendrix in the master planned community of Summerlin, Nevada.

We loved his quirkiness during trial when your intelligent aggressive lawyer {as you say} G. Luke Ciciliano was chastised by the former Nevada Supreme Court Chief Justice Miriam Shearing for blabbering incoherently to himself while facing away from the Justice and to the back of the courtroom. He claimed in his apology to the Justice that he was talking to the empty jury box pretending there were people there, a ghost jury if you will! Sweet!

So you didn’t know that filed an appeal? Oops! We hope that G. Luke Ciciliano hasn’t been blowing sunshine up your *ss! We hope G. Luke Ciciliano isn’t telling you everything is all well and good; of course if the wheels fall off you can always declare bankruptcy. Oh you’ve already done that. Okay then were fresh out of advice! But we do know if you don’t prevail in your appeal our law firm is going to seek all fees awarded by Judge Shearing totaling in excess of {$43,000.00} forty three thousand dollars.

NOTICE:

Shannon Hudnell; It is not our intention to mimic your behavior and punish you for your transgressions against us. We simply pray that you will leave us and all other people alone. Shannon Hudnell you are a menace to society inserting your untreated “ism” and personality disorders where they do not belong, mainly in other people’s lives which is probably a symptom of your deep seeded paranoia. Please sanitize all of your listings regarding us and delete any and all references to us, our names, our addresses, {both home and business}, professions, phone numbers and our artistic interests so your rip off reports can die and ascend to online rip off report heaven. When you have complied with this simple request and court order we will remove our postings of you.

Thank you!

STOP INTERNET PREDATORS NOW!!!

If you have been terrorized, threatened, harassed, stalked, stalked by proxy

or cyber stalked by Shannon Hudnell aka Shannon Hart or anyone or suspect Shannon Hudnell or any other person of committing any of the aforementioned acts against you or your family please contact us: